[Proposed] Order Appointing Lead Plaintiff and Approving Selection of Lead Counsel — In re January 2021 Short Squeeze Trading Litigation (Dkt. 144-3, S.D. Fla.)

Summary

A [Proposed] Order Appointing Lead Plaintiff and Approving Selection of Lead Counsel in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-2989-MDL-ALTONAGA/Torres), in the U.S. District Court for the Southern District of Florida, entered April 14, 2021 as Document 144-3 (2 pages) with the motion of Eric Quat, Aaron Fassinger, Mike Ross, Igor Kravchenko, Michael McFadden and Tenzin Woiser. The proposed order, drafted for entry by Hon. Cecilia M. Altonaga, would grant the motion under 15 U.S.C. § 78u-4 and appoint the movants Lead Plaintiffs for the Class with sole authority over the federal securities claims in the multidistrict litigation. The order would also appoint Bursor & Fisher, P.A. as Lead Counsel with enumerated powers, from presenting the Lead Plaintiffs' positions to the Court to conducting settlement negotiations.

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-2989-MDL-ALTONAGA/Torres

IN RE: JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION

This Document Relates to: All Actions Involving Federal Securities Laws

[PROPOSED] ORDER APPOINTING LEAD PLAINTIFF AND APPROVING
SELECTION OF LEAD COUNSEL

Before the Court is Proposed Lead Plaintiffs Eric Quat, Aaron Fassinger, Mike Ross, Igor
Kravchenko, Michael McFadden, and Tenzin Woiser’s (collectively “Movants”) Motion to
appoint them as Lead Plaintiffs and approve their selection of counsel, Bursor & Fisher, P.A.,
pursuant to 15 U.S.C. § 78u-4.  After review of the motion and accompanying memorandum of
law, and exhibits thereto, as well as oral argument, if any, Movants’ Motion to Appoint them as
Lead Plaintiffs and Approve Their Selection of Counsel is GRANTED.

  IT IS HEREBY ORDERED that Movants are appointed as Lead Plaintiffs for the
Class pursuant to 15 U.S.C. § 78u-4, and have sole authority to bring claims under federal
securities laws as it relates to the subject matter of the cases involved in the present multidistrict
litigation;

IT IS FURTHER ORDERED that Movants’ selection of counsel, Bursor & Fisher,
P.A., is hereby approved, and Bursor & Fisher, P.A. is hereby appointed Lead Counsel with sole
authority to prosecute the claims under federal securities laws as it relates to the subject matter of
the cases involved in the present multidistrict litigation, this includes sole authority to do the
following:

Case 1:21-md-02989-CMA   Document 144-3   Entered on FLSD Docket 04/14/2021   Page 1 of 2

1. Determine and present to the Court and opposing parties the position of the Lead
Plaintiffs and class members on all matters arising under the federal securities laws,
including preparing all pleadings and briefing and arguing of motions;
2. Enter into stipulations with opposing counsel as necessary for the conduct of the
litigation;
3. Coordinate the initiation and conduct of discovery on behalf of Lead Plaintiffs and class
members consistent with the requirements of the Federal Rules of Civil Procedure;
4. Hire expert witnesses and consultants on behalf of the Lead Plaintiffs and putative class
members, as needed to prepare for class certification or trial, and advance other costs that
may be reasonable and necessary to the conduct of the litigation;
5. Conduct settlement negotiations on behalf of the Lead Plaintiffs and the class, and, if
appropriate, to enter into a settlement that is fair, reasonable, and adequate on behalf of
the class members;
6.  Monitor the activities of all counsel to ensure that schedules are met and unnecessary
expenditures of time and funds are avoided; and
7. Perform such other duties as may be incidental to the proper prosecution and
coordination of activities on behalf of Lead Plaintiffs and class members or authorized by
further order of this Court.
SO ORDERED
Date:

_______________________________

HON. CECILIA M. ALTONAGA

UNITED STATES DISTRICT JUDGE
Case 1:21-md-02989-CMA   Document 144-3   Entered on FLSD Docket 04/14/2021   Page 2 of 2

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